Arizona v. Roberson
486 U.S. 675 (1988)
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Rule of Law:
Once a suspect in custody has invoked their Fifth Amendment right to counsel, the police are prohibited from initiating further interrogation regarding any offense, including one unrelated to the initial arrest, until counsel has been made available.
Facts:
- On April 16, 1985, Roberson was arrested at the scene of a recently completed burglary.
- The arresting officer advised Roberson of his Miranda rights.
- Roberson stated that he 'wanted a lawyer before answering any questions.'
- Roberson's request for counsel was recorded in the arresting officer's written report.
- Three days later, on April 19, 1985, while Roberson remained in custody, a different officer interrogated him.
- This second officer was investigating a different burglary that had occurred on April 15.
- The interrogating officer was not aware that Roberson had previously requested counsel.
- After receiving a fresh set of Miranda warnings, Roberson made an incriminating statement about the April 15 burglary.
Procedural Posture:
- In the prosecution for the April 15 burglary, Roberson's counsel filed a motion to suppress his incriminating statement.
- The Arizona trial court granted the motion to suppress.
- The State of Arizona appealed the trial court's order to the Arizona Court of Appeals, where the State was the appellant and Roberson was the appellee.
- The Arizona Court of Appeals affirmed the trial court's suppression order.
- The Arizona Supreme Court denied the State's petition for review.
- The United States Supreme Court granted certiorari.
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Issue:
Does the Fifth Amendment's prohibition against police-initiated interrogation of a suspect in custody who has requested counsel, as established in Edwards v. Arizona, apply when the second interrogation concerns a crime unrelated to the one for which the suspect was initially arrested?
Opinions:
Majority - Justice Stevens
Yes. The prophylactic rule established in Edwards v. Arizona, which bars police from reinitiating interrogation after a suspect in custody has requested counsel, is not offense-specific and applies even when the subsequent interrogation concerns a separate and unrelated investigation. The Court's reasoning is that the bright-line rule from Edwards provides necessary clarity and ease of application for law enforcement. The presumption that a suspect who requests counsel feels unable to cope with the pressures of custodial interrogation does not disappear simply because the police wish to question them about a different crime. Roberson's request for a lawyer before answering 'any questions' was broad and unqualified, indicating a general unwillingness to deal with police interrogation without legal assistance. The fact that the second officer was unaware of the initial request is irrelevant, as the focus of the Edwards rule is on the suspect's state of mind and the responsibility rests with the law enforcement agency to maintain procedures that honor such requests.
Dissenting - Justice Kennedy
No. The Edwards rule is a prophylactic measure designed to prevent police from 'badgering' a suspect, a risk that is minimal when a subsequent interrogation is for a separate and independent investigation by different officers. The majority's extension of the rule is unwarranted and will unnecessarily hamper legitimate law enforcement efforts by preventing police from questioning a suspect about unrelated major crimes. Providing a fresh set of Miranda warnings for the new investigation strikes an appropriate balance, protecting the suspect from coercion while allowing police to investigate. The Court's rigid, per se rule wrongly presumes that a suspect's decision not to talk about one crime without a lawyer automatically extends to a completely different crime that the suspect was not even aware was under investigation.
Analysis:
This decision significantly strengthens the Edwards rule by making it a broad, non-offense-specific protection. It clarifies that a suspect's invocation of the Fifth Amendment right to counsel creates a comprehensive shield against any further police-initiated interrogation, irrespective of the subject matter. The ruling firmly rejects a case-by-case analysis in favor of a clear, bright-line rule, prioritizing certainty and the protection of the suspect's right over police investigatory flexibility. This places a significant procedural burden on law enforcement agencies to track counsel requests diligently, as an individual officer's ignorance of a prior request is not an excuse for a violation.
